Before Hearing Commissioners under: in the matter of: the Resource Management Act 1991 notices of requirement and resource consent applications by the NZ Transport Agency and Hamilton City Council for the Southern Links Project Statement of evidence of Ken Read (Contaminated Land) on behalf of the NZ Transport Agency and Hamilton City Council Hearing date: 21 July 2014 Dated: 12 June 2014 REFERENCE: Suzanne Janissen ([email protected]) Jo Bain ([email protected]) Chapman Tripp T: +64 9 357 9000 F: +64 9 357 9099 23 Albert Street PO Box 2206, Auckland 1140 New Zealand www.chapmantripp.com Auckland, Wellington, Christchurch Tompkins Wake T: +64 7 839 4771 F: +64 7 839 4855 Westpac House 430 Victoria Street PO Box 258, DX GP20031 Hamilton 3240 New Zealand www.tomwake.com STATEMENT OF EVIDENCE OF KEN READ ON BEHALF OF THE NZ TRANSPORT AGENCY AND HAMILTON CITY COUNCIL INTRODUCTION 1 SCOPE OF EVIDENCE 2 SUMMARY OF EVIDENCE 2 MY ROLE IN THE PROJECT 3 EXISTING ENVIRONMENT 4 CONTAMINATED LAND ASSESSMENT CRITERIA 5 ASSESSMENT OF CONTAMINATED LAND EFFECTS 7 MITIGATION OF CONTAMINATED LAND EFFECTS 8 COMMENTS ON SUBMISSIONS 9 COMMENTS ON S42A REPORT AND RECOMMENDED CONDITIONS 9 CONCLUSIONS 11 Annexure A - Table 1: Potentially Contaminated Properties affected by the Project 12 Annexure B – Figure 6: Location of potentially contaminated properties 13 100059484/3424455 1 STATEMENT OF EVIDENCE OF KEN READ ON BEHALF OF THE NZ TRANSPORT AGENCY AND HAMILTON CITY COUNCIL INTRODUCTION 1 My full name is Kenneth John Read. 2 I hold a Bachelor of Science (Honours) in Geology from Edinburgh University, graduating in 1982, and a Masters of Science in Engineering Geology from Newcastle University, graduating in 1984. 3 I have been a Chartered Professional Engineer (CPEng) since 2009, and I am a member of IPENZ. I am also a Chartered Geologist (CGeol (UK)) since 1994 and a Fellow of the Geological Society. 4 Since 1984, I have predominantly worked in engineering consultancies providing site investigation, geotechnical and engineering geological advice and design services for many civil engineering and development related works. This has included domestic, retail and industrial developments, highways, dams, water and waste water treatment works and bridges. Since 1988, many of my projects have involved development on potentially contaminated sites in the United Kingdom and New Zealand. 5 From 1992 to 1995, I worked for a UK site investigation contractor as its Principal Geotechnical Engineer. The role involved planning, managing and reporting on site investigations for structures, motorways, tunnels and housing developments. Between 1995 and 2006, I worked in several consultancies variously as a Principal and Senior Engineering Geologist/Geotechnical Engineer. Projects comprised domestic housing developments, prisons, highways, sea outfalls, landfills and industrial developments. 6 I moved to New Zealand in 2006, taking up the position of Senior Engineering Geologist with Opus International Consultants in Hamilton. I was made Geotechnical Group Manager in Hamilton in 2011. In that role, I have been responsible for assessment of contaminated land effects of the Tamahere-Cambridge and the Hamilton Sections of the Waikato Expressway. 7 I have recently presented geotechnical evidence in support of the Ruakura Development Plan Change to a Board of Inquiry on behalf of Tainui Group Holdings. 8 My evidence is given in support of notices of requirement (NORs) and applications for resource consents lodged by the NZ Transport Agency (the Transport Agency) and Hamilton City Council (HCC) on 9 August 2013 in relation to the construction, operation and maintenance of the Southern Links Project (Project). 100059484/3424455 2 9 I am familiar with the area that the Project covers, and the existing State highway and the local roading network in the vicinity of the Project. 10 I have prepared the Preliminary Contaminated Land Report (Contaminated Land Report) which is provided as Appendix R to the Assessment of Environmental Effects (AEE) lodged in support of the NORs. 11 I confirm that I have read the ‘Code of Conduct for Expert Witnesses’ contained in the Environment Court Practice Note 2011. To the extent that the Code is relevant to my statement of evidence, my evidence has been prepared in compliance with that Code in the same way as I would if giving evidence in the Environment Court. In particular, unless I state otherwise, this evidence is within my sphere of expertise and I have not omitted to consider material facts known to me that might alter or detract from the opinions I express. SCOPE OF EVIDENCE 12 My evidence will deal with the following: 12.1 Summary of evidence; 12.2 My role in the Project; 12.3 Existing environment; 12.4 Contaminated land assessment criteria; 12.5 Assessment of contaminated land effects; 12.6 Mitigation of contaminated land effects; 12.7 Comments on submissions; 12.8 Comments on s42A Report and recommended conditions; and 12.9 Conclusions. SUMMARY OF EVIDENCE 13 The work I have carried out to date has identified a number of properties within the designation footprint that have, or have had, a use or uses that could potentially lead to soil contamination. 14 Although those properties have been identified as “potentially contaminated”, the activity that has led to that classification may not have caused contamination or may not have been within the 100059484/3424455 3 area of the property within the designation footprint. While further investigation is needed and will be undertaken at the detailed design stage of the Project, if any contamination is present at those sites, in my experience, in many cases it is likely to be limited to small localised areas. 15 I am not aware of any work undertaken to date to confirm the presence of contaminated soils on the areas of these properties affected by the designation. 16 The rural nature of much of the area under consideration means that the majority of potential contaminants arise from the use of agrichemicals (residual pesticides and herbicides) and farm waste disposal (offal pits and farm tips). 17 Some commercially derived contamination is possible at the northern end of State Highway 3 (SH3), and industrial derived contamination may be present at the junction of the east west link with the existing State Highway 1 intersection of Kahikatea Drive and Greenwood Street. 18 It is unlikely that all potentially contaminated properties within the proposed designation have been identified to date. This is because my work to date is a largely desk-based study of records that may not be complete. Further, the majority of agricultural/rural contamination arises from activities that are themselves unrecorded (e.g. farm tip/offal pits), or the locations of which are unrecorded (e.g. sheep dips and spray mixing). 19 I consider that provided further investigation and assessment of potentially contaminated properties is made at the detailed design stage, and that it is undertaken in accordance with the relevant legislation and guidance that applies at the time, the potential hazards posed by soil contamination to the environment and human health arising from the Project can be appropriately mitigated and managed. 20 I have reviewed the s42A Report and, subject to minor amendments, support the inclusion of a Contaminated Soil Management Plan (CSMP). I consider that any contaminated land effects will be adequately avoided, remedied or mitigated through the implementation of the CSMP. MY ROLE IN THE PROJECT 21 I have been involved in the Project since November 2010. My role was initially to carry out a preliminary appraisal of potentially contaminated land present within the Southern Links Study Area. 100059484/3424455 4 22 In February 2011, I reported this work in my report entitled “Southern Links, Contaminated Land Assessment Preliminary Appraisal Report”).1 For this work, I obtained historic and present land use data from Waikato Regional Council (Waikato RC), Hamilton City Council (HCC), and Waipa and Waikato District Councils (Waipa DC and Waikato DC). I also participated in an area wide site visit to familiarise myself with the area and to look from the road side for unrecorded potentially contaminative activities such as farm tips. 23 In April 2012, I prepared a report entitled “Southern Links, Scheme Assessment, Preliminary Contaminated Land Assessment”.2 In this report, I assessed the possibility of potentially contaminated sites being present within the better defined route corridors known as the ‘Preferred Network’ being considered at that time. This report was based on data obtained for my previous report. 24 In mid 2013, I was then instructed by the Transport Agency and HCC to prepare the Contaminated Land Report for the Project, lodged as part of the AEE as Appendix R.3 25 I have not carried out any further work with respect to contaminated land in the Project area since lodgement of the NORs in August 2013, nor do I consider it necessary to do so for the purposes of preparing my evidence. EXISTING ENVIRONMENT 26 Much of the Project area is rural. While the rural land is mainly pasture, some food crops are grown. Isolated farm houses and pockets of residential development are present, with some operative and now closed orchards. In these areas, potential contaminative activities are primarily associated with the use of pesticides and herbicides. There are also possible sheep dips, offal pits and farm tips, the locations of which are seldom recorded. 27 Industrial or commercial land uses within the Project area are concentrated at the northern end of the proposed State Highway 1 (SH1) extension at Kahikatea Drive and at the southern end of the SH3 realignment close to the Hamilton Airport. In these cases, the nature of any potential contamination is closely linked to each particular industrial or commercial activity. 1 “Southern Links, Contaminated Land Assessment Preliminary Appraisal Report” (ref G2896, Issue 1, dated February 2011). 2 “Southern Links, Scheme Assessment, Preliminary Contaminated Land Assessment” (G3012, Issue 1, dated April 2012). 3 “Southern Links, Notice of Requirement, Preliminary Contaminated Land Assessment” (G3145, Issue 1, dated August 2013). 100059484/3424455 5 28 The dominant surface water features in the study area is the Waikato River and associated tributaries. The Waikato River flows south-east or north-west along the eastern margin of the Project area, with tributaries in generally shallow valleys tending primarily south-west to north-east across much of the Project area. These valleys develop into major incised gullies towards the Waikato River. 29 There are a small number of minor ponds and lakes associated with some of the tributary streams. 30 In the west of the area, the much more flat lying Rukuhia Swamp is criss-crossed by a series of drains. 31 Waikato Regional Council list eleven consented surface abstraction points within the Project area; six of which are from the Waikato River, the remainder are thought to be from ponds in the central part of the study area.4 I have assumed these abstraction points to be for domestic and agricultural supply. 32 Groundwater is very shallow in the west of the Project area over the Rukuhia Swamp. To the east of the Project area, groundwater level is thought to be controlled by the Waikato River, and local variation in the underlying geology, with perched water levels possible in the mixed soil horizons present. 33 Groundwater flow is expected to be predominantly towards the Waikato River with some local influences possibly towards the small lakes and ponds seen in some areas. I would expect flow rates to be highly variable in the various soil types across the study area. 34 Waikato RC lists fifteen consented groundwater abstraction points.4 It is likely however that a number of rural properties in the area may have shallow water bores that are unrecorded. These bores are expected to be for domestic and agricultural use. CONTAMINATED LAND ASSESSMENT CRITERIA 35 The identification, assessment and management of contaminated land in New Zealand is managed under: 4 35.1 The “Resource Management (National Environmental Standard for Assessing and Managing Contaminants in Soil to Protect Human Health) Regulations 2011” (NES); and 35.2 Contaminated Land Management Guidelines No.1, Reporting on Contaminated Sites in New Zealand, Ministry for the Environment, 2003 (MfE Guidelines). Waikato Regional Council web site: Maps - This is a GIS interactive map facility which was searched for consented ground and surface water abstractions. 100059484/3424455 6 36 On a local level the management of contaminated land is governed by the Waikato Regional Plan, Section 5.3 “Contaminated Land” and Section 4 of the Proposed Hamilton City District Plan “Development Suitability”. The Hamilton City District Plan focuses on effects on human health and the Regional Plan focuses on effects on the natural environment. 37 Section 9 of the Waikato District Council Plan and Section 19 of the Proposed Waipa District Plan both seek to manage environmental and human health risks associated with contaminated land and associated remedial works. All of my earlier reports referred to the MfE Guidelines, and my Contaminated Land Report acknowledged the introduction of the NES, which was enacted in January 2012, after my earlier reports were prepared.5 38 My Contaminated Land Report is essentially a ‘Preliminary Site Inspection’ report, as defined in the MfE guidance and the NES, which identifies potentially contaminated sites. 39 The Ministry of the Environment has prepared the Hazardous Activities and Industries List (HAIL) which is widely used to identify properties that may have hosted potentially contaminative activities. Waikato RC is working with HCC and Waipa DC and Waikato DC to compile a register of properties within the Region where HAIL activities have historically or are currently being carried out. This register is known as a ‘Selected Land Use’ list. Regional Councils also hold records of any works being carried out to remediate contaminated sites. The Selected Land Use Registers (SLURs) were the primary source of potentially contaminated site identification used in my Contaminated Land Report.6 40 As described in my Contaminated Land Report,7 the SLURs held by Waikato RC, Waikato DC and Waipa DC and HCC are a work in progress and may not be complete. Further, they identify entire properties as potentially contaminated, whereas the activity that has caused this listing may only have been restricted to a small or isolated area within that property. 41 I identified a number of sites as potentially contaminated based on a previous or existing HAIL land use. At this time, I have not been instructed to undertake any further work to confirm the presence of contaminated soils on these sites or any other sites affected by the NORs, nor do I consider it necessary to do so at this stage. 5 Contaminated Land Report, pages 1 and 2. 6 Contaminated Land Report, page 6. The SLURs contain information about confirmed contaminated sites and potentially contaminated sites (using the HAIL classification). 7 Contaminated Land Report, page 6. 100059484/3424455 7 42 Under the NES and MfE Guidelines, a staged approach should be adopted for further investigation and assessment of sites identified as potentially contaminated. This comprises preparation of: 43 42.1 A Detailed Site Investigation and Report (DSI, possibly multi-phased); 42.2 A Remediation Action Plan (RAP); 42.3 A site verification report (SVR) describing and recording the remedial works carried out and the condition of the site on completion of these; and 42.4 A Monitoring and Management Plan, if future monitoring of the remediated site is required. At the design stage, resource consents for associated earthworks and possible disposal of contaminated soils may be needed in compliance with the NES, the Regional Plan and the District Plans. ASSESSMENT OF CONTAMINATED LAND EFFECTS 44 Undertaking earthworks on contaminated land can expose site workers, people on neighbouring properties, surface water courses and groundwater to potentially harmful contaminants, if such contaminants are released and are present in concentrations above the thresholds identified in the NES. 45 Typically, the pathways for harm to people are via skin contact, inhalation and ingestion. In most cases, the risks of this potential harm being realised can be managed by conventional good engineering practice, by good hygiene and safety practice during construction breaking these pathways.8 46 The release of any contaminants to surface water can be controlled by best practice erosion and sediment control measures.9 47 Release of contaminants to groundwater however needs to be assessed on a case by case basis, looking at the individual site geology and the nature of the contamination. I have identified in my Contaminated Land Report that groundwater is a high risk receptor of potential contamination throughout the area.10 8 Contaminated Land Report, pages 7 and 8 - ref. G3145. 9 Such practices will form part of the applications for resource consents for the Project, and required by consent conditions. The resource consent applications will be prepared following detailed design. 10 Contaminated Land Report, pages 8. 100059484/3424455 8 48 In Annexure A to my evidence, I provide a list of those sites identified from the records obtained as potentially contaminated, together with the HAIL activity, and a qualitative description of where the maximum risk of encountering contamination lies. The locations of these sites are shown in Figure 6 of the Contaminated Land Report, a copy of which is appended to my evidence as Annexure B.11 49 Following good practice and in compliance with current legislation, I consider that further investigation of these sites will be necessary to confirm or otherwise the presence and nature of any contamination (via a DSI). If contaminated soils are present, an RAP will be needed, followed by preparation of a SVR. I recommend that the requirements for these steps be incorporated into the CSMP. MITIGATION OF CONTAMINATED LAND EFFECTS 50 Provided the following recommendations made in Section 6 of my Contaminated Land Report12 are followed during latter stages of the Project, I consider that the potential risks posed by contaminated soils can be suitably managed: 50.1 All works associated with the investigation, assessment and remediation of contaminated land must be overseen and controlled by a Suitably Qualified and Experienced Practitioner (SQEP) as required by the NES. 50.2 That assessment should comprise the following staged approach – detailed assessment of the documented history of the property, field investigation of the property, assessment of consequential effects on the network design and construction methodologies, risk assessment of the site and potential risks to human health and the environment posed by any contamination found must be assessed.13 51 At the detailed design and resource consent stage, it is my experience that suitable resource consent conditions can be included to ensure compliance with MfE guidance, the NES and relevant Regional and District Plan provisions. 52 As discussed below, I support the inclusion of a CSMP as proposed by the s42A authors. 11 Note that Figure 6 (Revision 1) is appended because it now includes the Hamilton Gardens site that was mistakenly excluded earlier. 12 Contaminated Land Report, pages 7 to 10. 13 I provide more detail regarding the risk assessment on page 9 of my Contaminated Land Report. 100059484/3424455 9 COMMENTS ON SUBMISSIONS 53 I have read submissions lodged on the Project. I have not identified any that specifically raise contaminated land effects. 54 I consider that provided the recommendations explained above are followed, any actual contamination that may be present on properties affected by the Project will be identified and managed appropriately, as required by the NES and the updated designation conditions. COMMENTS ON S42A REPORT AND RECOMMENDED CONDITIONS 55 I have read the s42A Report prepared on behalf of HCC, Waipa and Waikato District Councils dated 30 May 2014 (s42A Report) and the Technical Specialist Report prepared by Dr Paul Heveldt (Appendix J to the s42A Report) (Specialist Report). I have no contrary comments to make on the contents of the s42A Report. 56 I note that Dr Heveldt considers my Contaminated Land Report is of sufficient coverage and detail to give confidence that contaminated land will be satisfactorily quantified at the time of construction and mitigated through the proposed conditions.14 57 The s42A authors note that Dr Heveldt considers the investigations undertaken to date to be appropriate, and that he agrees with the recommendations in my Contaminated Land Report.15 58 The s42A report notes that my assessment may not have taken into consideration potentially contaminated sites within Hamilton City.16 To clarify, my assessment did include the identification of potentially contaminated land within Hamilton City. While, several sites were identified, the majority of these sites are not within or in proximity to the proposed designation boundaries. However, I accept that one site, the Hamilton Gardens, is crossed by the proposed designation but, in error, was not included as a highlighted property at Figure 6 or detailed in the body of the Contaminated Land Report. This has been corrected in Annexure B to this evidence. 59 At the detailed design stage, Hamilton Gardens and all other properties within the NOR in Hamilton City will need to be assessed in detail as per all other areas within the NOR. 60 Subject to some minor amendments, I support the conclusions and proposed conditions discussed in Section 5 of the Specialist Report 14 Specialist Report, sections 4.1 and 5. 15 Section 42A Report, at section 16.5. 16 Section 42A Report, at section 16.5. 100059484/3424455 10 carried through into the s42A Report.17 In particular, I agree with the recommendation for a specific condition requiring the preparation and implementation of a CSMP. 61 I propose the following amendments be made to the CSMP conditions recommended in the s42A Report:18 Contaminated Soil Management Plan 23.1 Prior to the commencement of construction, the Requiring Authority shall engage a Suitably Qualified and Experienced Practitioner to prepare a Contaminated Soil Management Plan (CSMP). The Requiring Authority shall adhere to the relevant requirements of the CSMP at all appropriate times during the Project. The purpose of the CSMP shall be to avoid, remedy or mitigate the adverse effects of any enabling works and the construction of the Project on human health and the environment which may result from the disturbance of contaminated soil/material. 23.2 The CSMP shall be provided to the Chief Executive Officer or nominee of the Territorial Authority for certification at least 40 working days prior to construction activities being undertaken. 23.3 As a minimum the CSMP shall include the following details: a) Details of any investigation, assessment, reporting and management of contaminated land or potentially contaminated land that has carried out; b) The measures to be undertaken in the handling, storage and disposal of all contaminated material excavated during the construction works; c) The soil validation testing that will be undertaken; d) The soil verification testing that will be undertaken to determine the nature of any contamination in excavated spoil and the potential reuse or disposal options for that spoil; e) How the placement of any re-used contaminated soil / material will be recorded and tracked; f) Measures to be undertaken in the event of unexpected contamination being identified during construction activities, including measures to: g) h) i. Assist with identification of unknown contaminated material; ii. Stop work or isolate the area once any such material is identified; The measures to be undertaken to: i. Protect the health and safety of workers and the public; ii. Control stormwater runon and runoff; iii. Remove or manage any contaminated soil; iv. Remediate any required sites. The measures to be undertaken to: 17 Section 42A Report, Appendix J. 18 Section 42A Report, Appendix A. 100059484/3424455 11 i. Identify any suspected asbestos; ii. Identify the type of asbestos and confirm the appropriate means by which it shall be removed; iii. Handle any asbestos containing material. 23.4 A Suitably Qualified and Experienced Practitioner shall supervise the implementation of Tthe measures required in condition 20.3 above. shall also include appointment of a Suitably Qualified and Experienced Practitioner to implement the actions identified in the CSMP. 23.5 At the completion of the construction of the Project, a validation report will be prepared by a Suitably Qualified and Experienced Practitioner in accordance with any Ministry for the Environment guidelines and the National Environmental Standard for Assessing and Managing Contaminants in Soil to Protect Human Health and submitted to the Chief Executive Officer or nominee of the Territorial Authority documenting the management of contaminated soil and evidence of appropriate disposal. The validation report shall include a record of all analytical results, volumes, tip receipts, and any incidents or complaints and how these were addressed. The validation report shall also identify any areas which need on-going monitoring and management by the Requiring Authority. 62 I particularly support the inclusion of the specific reference to asbestos in the s42A author’s proposed conditions as in my experience asbestos containing materials are a common occurrence in farm tips (recommended condition 20.3(h)). 63 My proposed updated conditions are incorporated in the planning evidence of Mr Eccles. CONCLUSIONS 64 I consider on the basis of works carried out to date, and provided the proposed methods of future identification, investigation and management of potentially contaminated land within the designation footprint are adopted and followed, construction of the Project can be carried out in a manner that adequately protects human health and the environment from possible adverse effects associated with contaminated soil. 65 I consider that the proposed conditions are adequate to protect human health and the environment from potential adverse effects caused by disturbance of contaminated soils. Kenneth Read 12 June 2014 Annexures A Potentially Contaminated Properties affected by the Project B Location of potentially contaminated properties. 100059484/3424455 12 ANNEXURE A - TABLE 1: POTENTIALLY CONTAMINATED PROPERTIES AFFECTED BY THE PROJECT SITE ID19 SITE NAME HAIL ACTIVITY(IES) 8818 Sunfruit Orchards Ltd A10, A17 Persistent pesticide bulk Greatest risk is at storage storage or use including and mixing/preparation sport turfs, market gardens, areas of pesticides. orchards, glass houses or spray sheds 9760 Narrows Golf Club A17 Storage tanks or drums for fuel, chemicals or liquid waste 11272 TJL Heritage A10 Persistent pesticide bulk Greatest risk is at storage storage or use including and mixing/preparation sport turfs, market gardens, areas of pesticides. orchards, glass houses or spray sheds 11326 Titoki Sands A10 Limited Persistent pesticide bulk Greatest risk is at storage storage or use including and mixing/preparation sport turfs, market gardens, areas of pesticides. orchards, glass houses or spray sheds 15305 D&T McDonalds Limited G3, G4 Landfill sites, Scrap yards including automotive dismantling, wrecking or scrap metal yards Margin of the property affected by the proposed designation. 27589 Hamilton Organic Recycling Centre G6 Hydrocarbon exploration or production including well sites or flare pits Likely to be localised in storage areas. About 25% of the property affected by the proposed designation. 79545 Animal I Breeding Services Ltd Any other land that has been subject to the intentional or accidental release of a hazardous substance in sufficient quantity that it could be a risk to human health or the environment Depending on the nature of the hazardous substance may be localised to the spill location. Records of clean up may be available. 574 Hamilton Gardens Gun clubs or rifle ranges, including clay targets clubs that use lead munitions outdoors, Landfill Site and any other land that has been subject to the intentional or accidental release of a hazardous substance in sufficient quantity that it could be a risk to human health or the environment. Greatest risk is release of landfill contents and any leachate given site proximity to the Wiakato River. C2, G3,I HAIL ACTIVITY Comment Greatest risk is at storage and mixing/preparation areas of pesticides. Note: these properties are directly affected by the proposed roading network and have a higher risk of encountering the area(s) where the potentially contaminative activity may have occurred. 19 The site ID number is that allocated by Waikato RC. 100059484/3424455 ANNEXURE B - FIGURE 6: LOCATION OF POTENTIALLY CONTAMINATED PROPERTIES !' #" %4C &&( B<4 ! & %# 1@ 4<24 =5 0 >? =>4? AF 20<<=A 14 A094< A= 8;>:F A70A A74 @ 8A4 2=<24? <43 8@ 3458<8A4:F 5? 44 ( ' $( %# ; 5? = 2=<A0;8<0A8=< #%%&' %# $ %# 1@ 4<24 =5 0 >? =>4? AF 20<<=A 14 A094< A= 8;>:F A70A 0 :0<3 B@ 4 70@ <=A =22B? ? 43 =< A74 >? =>4? AF " & %# H !8<8@ A? F 5=? A74 <C8? =<;4<A =<A0;8<0A430<3 !0<064;4<A B834:8<4@ H &2743B:4 0G0? 3=B@ 2A8C8A84@ 0<3 <3B@ A? 84@ 8@ A %#( %&%# %# %% ' !%#% %# !, &' %, % %# &#! %# 1 * + ; $ %# #! #$( & !%, ( % %# $# # " * # # # %# $ " % %# * %# #* %# % * ## % #) , %# =<A0;8<0A43 >? =>4? 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A094< A= A74? 2= 58? ; =? 4:8;8<0A4 A74 >=@ @ 818:8AF =5 @ =8: < %# * ## %( "' 48 2=<A0;8<0A8=< 11272 21 * + ' 78@ 586B? 4 70@ 144< 2=;>8:43 5? =; 30A0 @ B>>:843 1F * 08>0 * 0890A= 0<3 0;8:A=< 8AF =B<28:@ 0<3 <C8? =<;4<A ** 0890A= %468=<0: =B<28: 0<3 1B + 74:3 #>B@ 0<3 42=; ( ) % ," & %# ' 74 5=::=D8<6 38@ 2:08;4? @ 0>>:F A= A74 8<5=? ;0A8=< @ 7=D< =< A78@ 86B? 4 +# " %# Disclaimer !0A0<68 # % " # ( " %# 34<A85843 0<3 8< >? 454? ? 43 <4AD=? 9 $ ' %# ' " " $ 34<A85843 11326 11272 %# * ' %# ! %# %!" %# ( %( #* %% " %# & " & % ) ) % % ' ! 8818 %# & * "! %# 1 + * Potentially Contaminated Properties %# " ' % ! % * ## " 3 + * 8818 " , % % %# &+, & % ) %# "* %# & # $ 15305 ( & " # % ) "& %# !' " %# % ) % ' 4;>:4 ) 84D %# % &' '( % ! %# * 574 3 * + 15305 %# " % # ;E3 4C8@8=< ? ;0: </ 8<9@/ =<A0;8<0A43/ 0<3/ 86/ 0<<=A0A43/ C/ 5=? .&=BA74? .!$/ #.=<A0;8<0A430<3 </ 8<9@ / / &=BA74? .$%#' ."- ' . & * $? 454? ? 43 "4AD=? 9 %# & ## %# % " % 26 + * ' % # ( ' % %# %# %# * 27589 % & "' ' ' && 23 + * ' &' % , 23 * + $ Legend ' & 86B? 4 %4C8@ 8=< &=BA74? <8<9@ $? 454? ? 43 "4AD=? 9 ± =20A8=< =5 $=A4<A80::F =<A0;8<0A43 $? =>4? A84@
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